Adult woman's right to marry chosen partner upheld, marriage annulment overturned for violating constitutional privacy and personal liberty

SC upheld an adult woman's right to marry her chosen partner, overturning HC's annulment of the marriage. The Court held that individual choice in marriage is a fundamental constitutional right protected under privacy and personal liberty. HC erred by exercising parens patriae power over a competent adult, treating her as vulnerable despite being capable of independent decisions. The judgment emphasized that social values cannot override constitutionally guaranteed freedoms, and State interference in personal choices has a chilling effect on liberty. NIA investigation into any criminal aspects may continue separately. Appeal allowed.

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Issues Involved:
1. Legality of the High Court's annulment of the marriage.
2. Application of the parens patriae jurisdiction.
3. The scope and limits of habeas corpus jurisdiction.
4. The constitutional rights of an adult to choose their life partner.
5. The role of the National Investigation Agency (NIA) in the investigation.

Detailed Analysis:

1. Legality of the High Court's Annulment of the Marriage:
The Supreme Court held that the High Court of Kerala erred in annulling the marriage between the appellant and respondent No. 9 in a habeas corpus petition. The High Court's decision was based on an incorrect understanding of its jurisdiction and the facts of the case. The Supreme Court emphasized that the High Court's role in a habeas corpus petition is limited to determining whether the individual is in illegal confinement. Once it was established that Hadiya was not under illegal confinement and had married out of her own free will, the High Court should have closed the case. The annulment of the marriage by the High Court was deemed an overreach and a violation of the constitutional rights of the individuals involved.

2. Application of the Parens Patriae Jurisdiction:
The Supreme Court criticized the High Court's invocation of the parens patriae jurisdiction, which is traditionally applied to protect those who cannot care for themselves, such as minors or individuals with mental incapacities. The Court noted that Hadiya, being a major and mentally competent, did not fall within this category. The High Court's application of this doctrine to annul the marriage was inappropriate and beyond its jurisdiction. The Supreme Court clarified that the parens patriae doctrine should be invoked only in exceptional cases and not to interfere with the personal choices of competent adults.

3. The Scope and Limits of Habeas Corpus Jurisdiction:
The Supreme Court reiterated that the primary purpose of a writ of habeas corpus is to provide an expeditious remedy against illegal detention. The Court emphasized that once it is established that the individual is not illegally detained, the court's jurisdiction ends. The High Court's further actions, including the annulment of the marriage, were outside the scope of habeas corpus jurisdiction. The Supreme Court underscored that the individual's right to liberty and freedom of choice must be respected, and the court should not impose its own views on the individual's personal decisions.

4. The Constitutional Rights of an Adult to Choose Their Life Partner:
The Supreme Court highlighted the fundamental right of an adult to choose their life partner, which is protected under Articles 19 and 21 of the Constitution. The Court emphasized that this right includes the freedom to marry a person of one's choice and that societal or parental disapproval cannot override this constitutional guarantee. The Court noted that the High Court's interference with Hadiya's choice of partner was a violation of her fundamental rights. The Supreme Court reaffirmed that personal autonomy and the right to make intimate decisions are central to individual liberty and dignity.

5. The Role of the National Investigation Agency (NIA) in the Investigation:
The Supreme Court allowed the NIA to continue its investigation into any matter of criminality, provided it does not encroach upon the marital status of Hadiya and Shafin Jahan. The Court clarified that the investigation should focus on any alleged criminal activities and not on the validity of the marriage. This distinction was made to ensure that the investigation does not interfere with the couple's right to live their lives as law-abiding citizens.

Separate Judgment by Dr. D.Y. Chandrachud, J.:
Dr. D.Y. Chandrachud, J. concurred with the judgment and added his observations, expressing anguish over the miscarriage of justice and emphasizing the need to protect individual liberties from paternalistic interventions. He highlighted the importance of respecting the autonomy of adults and ensuring that constitutional freedoms are upheld. He also underscored that the High Court's actions were a serious transgression of constitutional rights and that personal choices regarding marriage and faith lie within the core zone of privacy, which is inviolable.

Conclusion:
The Supreme Court allowed the appeal, set aside the High Court's order annulling the marriage, and emphasized the importance of respecting individual autonomy and constitutional rights. The investigation by the NIA was permitted to continue, provided it does not interfere with the marital status of the individuals involved.

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